CASE: 18 month old accidentally shot in head when off duty police officer accidentally discharged his weapon which went through the floor of his apartment, and ceiling of apartment beneath, striking the sleeping baby in the head. Plaintiff showed negligent hiring and negligent issuance of firearm. The deputy had recently been released from a mental unit; there was no meaningful check of his background and the firearm assigned to him had a “hair trigger” (the spring had been filed down by someone before him). The child had recovered relatively well.